EPA’s latest draft guidance focuses on reducing potential risks from PFOA and PFOS in biosolids. While it does not create new federal requirements for industrial facilities, it could influence how wastewater utilities identify and manage PFAS entering their systems.
When industrial wastewater enters a municipal treatment system, the water itself is only part of the story.
Wastewater treatment plants separate solids from liquids during treatment. Some of those solids may eventually be processed into biosolids and applied to agricultural land, reclamation sites, golf courses, parks, or other properties as a soil amendment or fertilizer.
That system depends on wastewater treatment plants being able to manage what enters through the sewer.
In July 2026, the U.S. Environmental Protection Agency released new draft guidance for reducing risks from PFOA and PFOS in biosolids.
An Important Distinction: This Is Draft, Voluntary Guidance
EPA’s new document is currently draft, voluntary guidance.
It does not create a new federal limit for PFAS in biosolids. It does not automatically change industrial discharge permits, and it does not create a new nationwide requirement for every industrial facility.
EPA is accepting public comments on the draft through September 4, 2026, and the document may change before it is finalized.
Even so, the guidance matters because it shows where regulators and wastewater utilities may be placing more attention. EPA is encouraging wastewater systems to identify where PFAS is entering their facilities and, when possible, reduce those sources before the compounds reach biosolids, treated water, or other parts of the environment.
For industrial facilities, that upstream focus may be the most important part of the discussion.
What Did EPA Release?
On July 1, 2026, EPA released its Draft Guidance for Reducing Risk from PFOA and PFOS in Biosolids.
The document offers recommendations for wastewater treatment plants, related facilities, landowners, farmers, state and Tribal agencies, and members of the public.
Rather than setting one nationwide concentration limit, EPA describes steps that may help reduce potential exposure, including:
- Identifying sources of PFAS entering wastewater systems
- Using pollution-prevention and industrial pretreatment strategies
- Monitoring sewage sludge and biosolids
- Evaluating how and where biosolids are used
- Considering risks connected with surface disposal and incineration
EPA also published an announcement explaining the purpose of the draft and the public-comment process.
The guidance reflects how complicated PFAS management can be. PFAS concentrations, soil conditions, application history, crops, groundwater, climate, and surrounding land uses can all influence potential exposure.
That makes it difficult to create one simple answer that works for every wastewater system or every community.
What Are Biosolids?
Wastewater treatment plants receive domestic sewage and, in many communities, wastewater from commercial and industrial facilities.
During treatment, liquids are separated from solids. The resulting semi-solid material is generally known as sewage sludge. When that material is treated to meet applicable requirements and is intended for beneficial use as a soil amendment or fertilizer, it is commonly referred to as biosolids.
EPA provides a helpful overview of how sewage sludge and biosolids are produced and managed.
EPA estimates that approximately 60% of sewage sludge generated in the United States is land applied in some form. Although biosolids are applied to less than 1% of U.S. farmland annually, land application remains an important and often cost-effective outlet for many wastewater utilities.
That also means a disruption to land application can create challenges elsewhere.
When biosolids cannot be land applied, wastewater plants may need to find additional landfill capacity, consider incineration, store material longer, or identify another approved outlet. Each option may bring higher costs, more transportation, limited capacity, or different environmental concerns.
How Does PFAS Enter Biosolids?
Wastewater treatment plants generally do not manufacture PFAS.
They receive PFAS from materials entering the collection system from many possible sources, including homes, businesses, landfills, commercial operations, and industrial facilities.
PFAS may be connected with products or processes involving:
- Water-, grease-, or stain-resistant coatings
- Metal plating and finishing
- Certain textiles and treated fabrics
- Paper and packaging treatments
- Firefighting foams
- Chemical manufacturing
- Electronics and semiconductor production
- Some cleaning agents, surfactants, waxes, and process aids
- Landfill leachate
- Wastewater from facilities that use or handle PFAS-containing materials
Not every facility in one of these categories necessarily discharges PFAS.
PFAS may also enter a facility through incoming water, raw materials, packaging, maintenance products, safety equipment, or contamination connected with activities that took place years ago.
That is one reason identifying the source can be difficult.
EPA maintains additional information about PFAS in sewage sludge and biosolids for readers who want a deeper look at how these compounds move through wastewater systems.
Conventional municipal wastewater treatment was generally designed to remove solids, nutrients, organic material, and other common pollutants. It was not originally designed to destroy persistent fluorinated compounds.
Some PFAS may remain in treated water, while some may collect in sludge. Exactly where the compounds end up depends on the type of PFAS and the treatment process being used.
Why Industrial Sources Are Receiving Attention
One of the clearest messages in EPA’s draft guidance is that reducing PFAS before it enters a wastewater treatment plant may be easier than trying to manage it once it has spread throughout the system.
The guidance points to industrial source reduction, pretreatment, and monitoring programs already being used in several states.
EPA highlights Michigan as one example. The state worked to identify significant PFAS sources entering municipal wastewater systems and used industrial pretreatment programs to reduce those loadings.
According to the draft guidance, seven Michigan wastewater treatment plants with industrial sources achieved reductions of up to 99% in PFOS concentrations in sewage sludge through these efforts.
That does not mean every industrial facility will face the same expectations or see the same results.
It does help explain why local wastewater utilities may begin asking more questions about PFAS. A utility cannot fully understand PFAS in its biosolids without first understanding where those compounds may be entering the system.
That could lead utilities to review their industrial-user lists, request sampling, ask facilities about materials used on site, or consider changes to local permit conditions.
Does the Guidance Create New Requirements for Industrial Facilities?
No, not by itself.
The document is draft, voluntary guidance focused on managing potential risks from PFOA and PFOS in biosolids.
It does not create a new federal discharge limit for every industrial user, and it does not automatically change an existing pretreatment or sewer-use permit.
Industrial requirements may still develop through other channels.
A state environmental agency, local sewer authority, or publicly owned treatment works may establish monitoring, reporting, pretreatment, or best-management requirements under its existing authority.
Some states have already introduced PFAS-specific biosolids policies, monitoring programs, land-application restrictions, or industrial source-control initiatives.
That means expectations may vary considerably from one location to another.
A manufacturer with facilities in several states could encounter different PFAS requirements at each location, even when the production process is similar.
EPA provides additional resources related to PFAS and industrial wastewater programs, along with training materials for wastewater authorities developing PFAS monitoring strategies within pretreatment programs.
What Could Change for Industrial Wastewater Generators?
The immediate effect of EPA’s draft guidance may be limited, but the broader direction is becoming easier to see.
Wastewater utilities are under increasing pressure to understand PFAS entering their systems. If a utility detects elevated PFAS concentrations in its sludge, biosolids, treated water, or receiving waters, industrial users may be among the sources it investigates.
Facilities could eventually experience:
- Requests to complete PFAS-use inventories
- Additional wastewater or process sampling
- New disclosure or reporting expectations
- Changes to local discharge permits
- Best-management-practice requirements
- Source-reduction requests
- Restrictions on particular waste streams
- Higher wastewater-management costs
- Greater scrutiny of landfill leachate or off-site wastewater
- Reduced access to municipal treatment for certain materials
These outcomes are not guaranteed, and they will not happen everywhere at the same time.
Still, industrial facilities should not assume that biosolids policy is only an issue for farmers or municipal wastewater plants.
Changes at the end of the wastewater-treatment process can eventually affect what a treatment plant is willing or able to accept at the beginning.
Why Testing Alone May Not Provide the Entire Answer
PFAS testing has improved, but it remains a specialized and sometimes complicated area.
EPA Method 1633 can measure 40 PFAS compounds in materials that include wastewater, biosolids, landfill leachate, soil, sediment, and other environmental samples.
EPA provides more detail about PFAS analytical methods and sampling research.
A laboratory result can identify compounds covered by the test, but facilities still need to understand what the result means in practical terms.
Important questions may include:
- Where is the PFAS entering the process?
- Is it present in raw materials, incoming water, packaging, cleaners, firefighting systems, or older residues?
- Is the sampled wastewater representative of normal operations?
- Are the concentrations consistent, intermittent, or linked to a particular production run?
- Can the stream be isolated?
- Can a PFAS-containing material be replaced or reduced?
- Would on-site treatment transfer the PFAS into another waste stream?
- Will the receiving wastewater facility accept the material?
Testing can be an important first step, but it works best when it is paired with a clear understanding of the facility’s processes.
Moving PFAS Is Not the Same as Destroying It
PFAS management is difficult partly because many treatment technologies separate or concentrate PFAS rather than destroy it.
For example, a treatment system may remove PFAS from water and transfer it into spent carbon, resin, foam, concentrate, sludge, or another residual.
The treated water may contain less PFAS, but the PFAS-containing residual still needs an approved destination.
That does not mean the treatment was unsuccessful. Separating PFAS may be necessary to protect a receiving system, meet an acceptance standard, or reduce the amount of liquid requiring specialized management.
It does mean facilities need to consider the full waste-management process before selecting a treatment approach.
Transportation, storage, disposal capacity, documentation, residual management, and long-term responsibility can all be just as important as the treatment technology itself.
EPA’s interim guidance on PFAS destruction and disposal provides additional background on the challenges associated with managing PFAS-containing materials.
What Should Industrial Facilities Do Now?
EPA’s draft guidance does not mean every facility should immediately begin a large PFAS sampling program.
A more practical first step is to understand where PFAS could potentially be present within the operation.
Facilities may want to review:
- Raw materials and chemical inventories
- Safety data sheets and supplier information
- Historical use of aqueous film-forming foam
- Surface treatments, coatings, plating baths, cleaners, and surfactants
- Wastewater generated during equipment cleaning or product changes
- Landfill leachate or waste received from outside sources
- Existing sewer-use and pretreatment permits
- Customer or supplier requirements involving PFAS
- Communications from the local wastewater authority
- State-specific PFAS rules and biosolids policies
Facilities should also understand where each wastewater stream goes.
Material discharged to a sewer, stored in a tank, sent to a treatment facility, mixed with another stream, or transported off site may be subject to different requirements and acceptance criteria.
That information becomes especially important if a wastewater utility begins investigating possible upstream PFAS sources.
This Is Part of a Larger Shift
EPA’s new guidance is not an isolated development.
In 2025, EPA released a draft sewage-sludge risk assessment for PFOA and PFOS, which helped inform the newer biosolids guidance.
Federal agencies, states, wastewater utilities, landowners, manufacturers, and waste-management companies are all looking more closely at how PFAS moves through products, wastewater, sludge, landfills, soil, water, and other parts of the environment.
The challenge is that a decision in one part of the system often affects the others.
Restricting land application may help protect certain properties, but it can increase demand for landfill or incineration capacity. Treating wastewater may reduce a liquid discharge but create a concentrated residual. Rejecting a waste stream at one facility may simply send it to another outlet that must still manage the same compounds.
There is rarely one simple solution.
For industrial facilities, the strongest starting point is to understand the wastewater before options become limited.
That means knowing how the waste is generated, what it may contain, where it currently goes, and what alternatives may be available if acceptance requirements change.
Planning Before Requirements Change
EPA’s draft PFAS biosolids guidance does not establish an immediate nationwide mandate for industrial wastewater generators.
It does, however, reinforce a direction that has been developing for several years: wastewater systems are being encouraged to identify PFAS sources and reduce significant loadings before those compounds reach biosolids, surface waters, or other parts of the environment.
Facilities that wait until a discharge is rejected or a permit changes may have fewer options and less time to respond.
Facilities that begin by understanding their processes, reviewing materials, communicating with wastewater partners, and evaluating contingency outlets will be better prepared as PFAS expectations continue to develop.
At Valicor, we work with industrial facilities to characterize and manage complex non-hazardous wastewater streams. When municipal discharge, land application, or another traditional outlet becomes limited, access to a broader treatment and transportation network can help facilities evaluate practical alternatives while keeping operations moving.
